Income Tax

Expenditure for earning interest income allowed u/s 57(ii) as nexus of loan & FDR not doubted

Expenditure for earning interest income allowed u/s 57(ii) as nexus between loan taken and amount invested in FDR not was doubted

ABCAUS Case Law Citation:
ABCAUS 3315 (2020) (05) ITAT

Important case law relied upon by the parties:
CIT Vs. RajendraPrasad Moody, [1978] 115 ITR 519 (SC)
astern Investments Ltd. v. CIT [1951] 20 ITR 1, 4 (SC)
Vodafone South Ltd. vs. CIT, [2015] 3781TR 410
Raj Kumar Sharma vs. ACIT

In this case, the appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals) in confirming the disallowance on account of expenditure claimed by the assessee u/s 57(iii) of the Income Tax Act, 1961 (the Act).

It was the case of the assessee that the interest expenditure had been incurred wholly and exclusively for the purpose of earning the interest income.

The assessee was an individual and had earned income under the head salary, house property, capital account and other sources during the year under consideration. 

The Assessing Officer (AO) selected the case of the assessee for scrutiny under CASS and accordingly notice u/s 143(2) of the Act was issued. 

During the year under consideration, assessee had taken loan  from  NBFCs for the purpose of making investment. However, due to non-materialization of deal the available funds of the assessee were invested by him in Fixed Deposit so as to earn interest income from the same.

After setting off the interest earned on FDRs to the interest paid on loan from NBFCs, the assessee incurred net interest loss.

However the AO made the disallowance u/s 57 of the Act by holding that the expenses were incurred for the purpose of investment was not substantiated by placing any material on   record except the FDRs.

The assessee filed an appeal before the CIT(A), who vide the impugned order upheld the addition.

The Tribunal observed that that the revenue authority had not doubted the nexus between the loan taken from NBFCs and the amount invested in FDR.

The Tribunal on the strength of the judgment of the Hon’ble Supreme Court, stated that it is a settled law that the deduction u/s 57(iii) of the Act will be allowable even if no income is earned by the assessee u/s 56 of the Act. The language of section 57(iii) of the act does not anywhere specifies that any income should have been earned as a result of the expenditure incurred.  It only specified that the purpose of expenditure should be that of earning income, it is mandatory that income should have been earned by the assessee.

Accordingly, the Tribunal opined that the addition in dispute was contrary to law and facts and therefore deleted the same.  

Download Full Judgment Click Here >>

Share

Recent Posts

  • ICAI

Applicability of Guidance Note on Financial Statements of Non-Corporate Entities/LLPs

Applicability of ICAI Guidance Note on Financial Statements of Non-Corporate Entities/LLPs for FY 2025-26 and 2026-27 ICAI has issued an…

2 days ago
  • Income Tax

Requirement of DIN referencing in Income Tax notices etc. and exceptions

CBDT has issued revised requirements of DIN referencing in Income Tax notices etc. and exceptions Section 292B of Income Tax…

4 days ago
  • Income Tax

Applicability of deeming fiction u/s 50C when property purchased & sold within same year

When property purchased and sold within same year both sale and purchase price has to be adopted by applying same…

4 days ago
  • ICAI

ICAI defers the effective date of Standard on Quality Management SQM1 and SQM2

ICAI defers the mandatory effective date of SQM 1 and SQM 2 The Council of ICAI, at its 451st Meeting…

4 days ago
  • Income Tax

Addition based on letter of District Magistrate not recovered during search deleted

Addition deleted as it was made on the basis of letter of District Magistrate which not recovered during the search…

5 days ago
  • Income Tax

CBDT clarification on threshold for TDS on interest by banks under Income Tax Act 2025

Banks not required to deduct TDS under Income Tax Act 2025 on interest income below threshold limit - CBDT clarification …

5 days ago